Defending against $2 billion in new regulatory costs

Over the past decade the American Wood Council has been very effective in shaping regulatory policies in the wood products industry

By closely engaging with key agency staff, possessing a thorough knowledge of the rulemaking process, and by constructively and openly sharing information about manufacturing processes, the industry has developed significant credibility with agency policymakers.

This has led to:

• Successfully shaping EPA’s survey of how proposed Wood MACT changes would impact the industry;
• Favorable reception at EPA of recommended work practices for proposed new kiln regulations;
• Retention of start-up, shutdown and malfunction exemptions from Wood MACT;
• Providing industry input to OSHAand other governmental entities that engage in rulemaking pertaining to workplace safety;
• Coordinating industry input to private organizations, such as the National Fire Protection Association (NFPA), that help establish consensus standards that influence workplace safety procedures.

The U.S. EPA is currently developing new regulations for wood products companies that could cost as much as $2 billion to implement. EPA’s actions are in response to a recent court decision overturning the 2004 Wood MACT and are expected to also include:

• A reassessment of the 2004 MACT for dryers and presses that could further tighten existing limits;
• Residual Risk Review: EPA must determine by 2012 if public health risks remain even after the 2004 MACT’s implementation;
• Revisit all Start-up, Shutdown and Malfunction (SSM) Exemptions: This review is being considered in light of a recent court decision that calls into question all SSM provisions which currently provide significant operating flexibility;
• Set a First-Ever New Source Performance Standard (NSPS) for the Industry: Though discussed in the late 1970s, an NSPS for wood products has never been pursued by EPA, which would set limits for a suite of additional air pollutants.

EPA is looking to the industry for leadership in developing a unified industry strategy for these environmental issues. That unity will be essential to our success and to help prevent environmental opponents from exploiting differences within the industry to weaken our advocacy and see the most stringent possible regulations imposed.

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